Overview
Licensed sponsors have ongoing reporting obligations to the Home Office. Failure to report required changes is a compliance breach and can result in a licence downgrade, suspension, or revocation.
Changes that must be reported within 10 working days
A sponsored worker does not turn up to start work on their first day
A sponsored worker is absent without permission for 10 or more consecutive working days
A sponsored worker's employment is terminated before the end date on their CoS
A sponsored worker's salary or hours change in a way that falls below the requirements on their CoS
A sponsored worker is convicted of a criminal offence
Changes that must be reported within 20 working days
The 20 working day deadline covers changes to your organisation, and it is broader than ownership and trading changes alone. Report all of the following through your SMS account within 20 working days of the change:
Replacing your Authorising Officer or Key Contact, or amending the details held for any of your key personnel.
Adding or removing Level 1 users.
A change to your organisation's name, address or contact details.
A change to your structure, including opening or closing a branch or a linked entity.
A change to your registration or accreditation status, which for a care provider means any change to your CQC registration.
Ceasing to trade, or entering an insolvency procedure.
A merger, takeover or similar change, or any other change of ownership.
A criminal conviction of any of your key personnel.
A change to your organisation's size or charitable status, because this affects your sponsorship fees and the Immigration Skills Charge you pay.
Some of these generate a submission sheet in the SMS. Sign it and return it within 5 working days. If you miss that deadline the Home Office refuses the request, and a pattern of late or missing documents can put the licence itself at risk.
If no Level 1 user can access the SMS, use the change of circumstances form instead. That is also the route for adding a Level 1 user, replacing a sole Authorising Officer, and surrendering a licence.
Maternity leave
Maternity leave must be reported on the Borderless platform as a change of circumstances. Upon return from maternity leave, this also needs to be reported to keep the Home Office record accurate.
Reduced hours after maternity return
When a worker returns from maternity leave on reduced contracted hours (for example moving from 48 hours to 30 hours, or restricting shift patterns), this must be reported as a change of circumstance via the Borderless platform within 10 working days of the change taking effect. The reduced hours must still produce a salary that meets both the minimum hourly rate for the SOC code (£12.82 for 6135/6136) and the £25,000 annual minimum on a pro-rated basis. If reduced hours mean the worker would fall below either threshold, the sponsorship cannot continue at those hours and the situation requires further review.
Sickness absence
Sickness absence of up to four weeks in a 12-month period does not normally breach sponsorship requirements. However, all periods of sickness should be recorded, and absences beyond four weeks may need to be reported. The Home Office assesses patterns of absence across the calendar year, not just consecutive weeks.
Short absences, sick leave and compassionate leave
Not every absence needs to be reported to the Home Office. A few days of sick leave, or a short period of compassionate leave, does not trigger a report. Record the absence internally in your usual way and process any statutory sick pay through payroll as normal.
The reporting obligation arises when a sponsored worker has been absent from work without pay, or on reduced pay, for 4 weeks or more in any 12-month period. At that point you must report the absence through the Sponsor Management System within 10 working days.
Short sick leave (days, not weeks): no report needed
Compassionate leave under 4 weeks unpaid: no report needed, but record the start date and monitor the total
Unpaid or reduced-pay absence reaching 4 weeks in 12 months: report on SMS within 10 working days
How the leave is recorded internally (paid holiday, unpaid leave, or compassionate leave) is a matter for your own HR policies. If a worker travels abroad during approved leave, they should carry their passport, which should be linked to their UKVI account. No additional travel documentation is required for a worker with a valid Skilled Worker visa.
Salary and hours changes
Sponsors must ensure that a sponsored worker is paid at least the salary stated on their CoS and that their hours are in line with what was recorded. If a worker is on a zero-hours contract, the Home Office can assess average hours over a cycle of up to 17 weeks. Minor, occasional shortfalls do not usually require reporting, but persistent or material shortfalls do.
Pay uplifts and salary increases
A pay increase, bonus, or cost-of-living uplift is not a reportable change provided the worker continues to perform the same role and the pay remains above the CoS rate. The Home Office is concerned with pay falling below the CoS threshold, not rising above it. There is no obligation to report a pay rise, and no need to assign a new CoS solely because a worker has been given more money for the same job.
When a sponsored worker moves to a new sponsor
If a sponsored worker is moving to a new sponsor, the incoming sponsor can assign a new CoS while the worker is still on their existing CoS with the previous sponsor. Having two live CoSs for a short overlap period is permissible and is the normal mechanism for a transfer. However, the outgoing sponsor must still report cessation of employment within 10 working days of the worker's final day. The outgoing sponsor cannot delay reporting while waiting for the new visa decision.
Change of work location
Where a worker moves permanently to a new location under the same sponsor, a change of circumstances report should be submitted. Temporary deployments to other sites (e.g. for cover or training) do not require a report, provided the role and employer remain the same.
Garden leave and the reporting trigger
Where a sponsored worker is given notice and placed on garden leave for some or all of the notice period, the garden leave does not bring forward your reporting obligation. Garden leave counts as a period of employment because the worker remains on payroll and under contract throughout. The trigger date for reporting the end of employment is the worker's last day of paid employment, not the last day they physically attended work. This date also drives the 60-day curtailment calculation if the worker's visa would otherwise still be valid.
Government guidance: https://www.gov.uk/government/publications/sponsor-a-skilled-worker